Implement Your 8130-3 Tag Privileges today!

14 C.F.R. 21.137(o) permits Production Approval Holders, like PMA companies, to issue their own 8130-3 tags for new parts (without recourse to a designee).

In order to issue 8130-3 tags, the Production Approval Holder (PAH) must develop and implement procedures addressing the selection, appointment, training, management, and removal of individuals authorized to issue 8130-3 tags. MARPA published a compliance checklist to aid our members last Fall, and it provides suggestions about how to draft the procedures. This was a members-only document so if you are a MARPA member and need a fresh copy of the checklist then please contact us directly.

On June 24, the FAA published additional guidance (Policy Number AIR100-16-110-GM16) to assist industry in using this new rule. Some key points raised in this new guidance include:

Some or all of these required procedures may already be in place for persons performing inspections, issuing or causing C of Cs to be issued, or performing other functions relating to the PAH’s compliance with 14 CFR §§ 21.146(c), 21.316(c) and 21.616(c). The PAH can rely on the existing procedures as the basis for issuing the 8130-3 tags, as long as they are tied together consistent with 21.137(o).

The PAH may select any individual to sign an 8130-3 on its behalf. These individuals may be inspectors, persons who currently issue certificates of conformity (C of C) to be issued or other person designated by the PAH to issue the form for the PAH.

Looking for training? A PAH may, but is not required to, use designee qualifications and training as a guide for authorizing individuals to sign 8130-3 tags. A PAH retains flexibility to choose how it intends to train the selected individual(s).

If 8130-3 tags are used for export, the 21.137(o) authorized representatives must be trained on:

a. 14 CFR part 21, subpart L,
b. Applicable bilateral agreements,
c. Advisory Circular 21-2, Special Requirements of Importing Countries, Appendix 2, and
d. Chapters 1, 2, and 4 of FAA Order 8130.21, Procedures for Completion and Use of the Authorized Release Certificate, FAA Form 8130-3, Airworthiness Approval Tag.
e. The training must include potential differences in how the forms are issued for domestic vs. export use.

Have existing DMIRS or other designees? A PAH implementing § 21.137(o) may retain its existing designees with functions related to 8130-3 tags until April 1, 2018 (by or before April 1, 2018, the FAA expects such designees to become redundant).

How do you implement? You may implement § 21.137(o) procedures without prior approval from the Manufacturing Inspection District Office. The changes are subject to normal FAA review, like any other change to a PAH’s quality system.

The revisions to the Maintenance Annex Guidance are requiring repair stations to increase their need for 8130-3 tags so it is important for PMA manufacturers to implement 21.137(o) programs to make those tags available.

If you are having problems implementing 8130-3 tag procedures because the local FAA office is not cooperating, then please let MARPA know so we can assist you.

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About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.